Douglas E. Wilson, Petitioner:
The People of the State of Colorado, Respondent: William Beaty, Petitioner:
The People of the State of Colorado, Respondent:
Certiorari to the Colorado Court of Appeals. Court of Appeals Case Nos. 09CA1073, 10CA742.
Relying on People v. Davis, 2015 CO 36 (released concurrently), the supreme court declines to adopt a new competency standard, pursuant to Indiana v. Edwards, 554 U.S. 164, 128 S.Ct. 2379, 171 L.Ed.2d 345 (2008), for mentally ill defendants who wish to waive the Sixth Amendment right to counsel. Therefore, the supreme court affirms the judgments of the court of appeals in both Wilson and Beaty because the court of appeals declined to adopt an Edwards standard in both cases.
For Petitioner: Alison Ruttenberg, Boulder, Colorado.
For Respondent: Cynthia H. Coffman, Attorney General, Patricia R. Van Horn, Senior Assistant Attorney General, Denver, Colorado.
For Petitioner: Benezra & Culver, P.C., Seth J. Benezra, Lakewood, Colorado.
For Respondent: Cynthia H. Coffman, Attorney General, Ryan A. Crane, Assistant Attorney General, Denver, Colorado.
RICE, CHIEF JUSTICE.
[¶1] We consider whether to adopt, pursuant to the United States Supreme Court's decision in Indiana v. Edwards, 554 U.S. 164, 128 S.Ct. 2379, 171 L.Ed.2d 345 (2008), a new competency standard for mentally ill defendants who wish to waive the Sixth Amendment right to counsel. Pursuant to our holding today in People v. Davis, 2015 CO 36, ¶ 1,
__ P.3d __, we decline to
create such a standard because Colorado's existing two-part framework for determining whether a defendant has validly waived the right to counsel affords trial courts sufficient discretion to consider a defendant's mental illness. As such, we affirm the court of appeals' decisions to retain the existing analytical framework in both People v. Wilson, No. 09CA1073,
__ P.3d __, 2011 WL 2474295 (Colo. App. June 23, 2011), and People v. Beaty, No. 10CA0742 (Colo. App. Oct. 27, 2011) (unpublished).
I. Facts and Procedural History